The EU's Markets in Crypto-Assets regulation (MiCA) is the most consequential piece of crypto legislation passed anywhere in the last decade. Phase 1 landed in 2024. Phase 2 is rolling out through 2026. The practical changes land first on EUR-denominated crypto invoices.
This article is informational only. It is not legal advice. Talk to a regulator-savvy lawyer before making any compliance decisions.
What MiCA covers (and doesn't)
MiCA regulates crypto-asset service providers (CASPs): exchanges, custodians, wallet providers, and payment infrastructure. It also regulates stablecoin issuers and a category called asset-referenced tokens (ARTs).
It does not regulate:
- The underlying cryptocurrency (Bitcoin, Ether) themselves
- DeFi protocols where there is no identifiable intermediary
- NFTs in most cases, with carve-outs
- Pure on-chain peer-to-peer transfers between non-custodial wallets
Phase 2: what's new
Phase 2 brings two things that matter for merchants:
1. Stablecoin reserve and disclosure rules
Stablecoin issuers operating in the EU must hold reserves backed 1:1 by liquid assets, audit those reserves quarterly, and disclose them publicly. Issuers that don't comply can't be marketed to EU consumers.
The practical effect for merchants: some stablecoins you accept today may not be MiCA-compliant tomorrow. Tether (USDT) is the most prominent gray-area issuer. USDC (Circle), EURC (Circle), and a handful of EU-issued stables are clearly compliant.
Your checkout page may need a disclosure surface for non-compliant stablecoins, depending on your customer base. We ship this automatically.
2. The CASP licence
If you operate a crypto-asset service in the EU, you need a CASP licence from your home Member State's regulator (BaFin in Germany, AMF in France, etc.). Most merchants accepting crypto via a CASP-licensed provider don't need their own licence. That is the licensed-provider model.
What this means for merchants
- If you accept EUR-denominated invoices, you'll see a new disclosure on the checkout for any non-compliant stablecoin. We ship this automatically; no integration change required.
- If you have EU-resident customers, the existing flow is unchanged for compliant stablecoins. USDC settlements, in particular, look exactly the same.
- If you operate your own CASP-licensed entity, you have new reserve and reporting obligations. Most of our merchants don't fall in this bucket; the few who do already have legal teams on it.
Timeline
What to do
If you're already routing EUR settlements through a licensed provider, you're mostly fine. The disclosure surface is the visible change, and we ship it for you. The CASP licence track is a "you'll know if it applies to you" situation.
If you're hand-rolling crypto acceptance with a non-licensed counterparty, this is the moment to reconsider that decision.
R. Sahin, halfin legal & policy
